Zullo Investment Group Inc

Fees and Compensation - Item 5

 Portfolio Management Services Fees
 For portfolio management services, CWI charges an annual fee of up to 1.80% of assets under management. Fees
 are payable quarterly in advance and are based on the value of assets on the last day of the previous calendar
 quarter. Fees will be pro-rated for the first partial quarter. The fees charged by sub-advisors for the management
 of portions of your portfolio are separate and distinct from our fees. Sub-advisors debit their fees directly from
 your account. We do not share in the fee charged by sub-advisors.

Capital Wealth Investments
Form ADV Part 2A

 Portfolio management fees are negotiable depending on factors such as the amount of assets under
 management, range of investments, and complexity of the client’s financial circumstances, among others. The
 agreed upon fee to be paid by the client will be clearly stated in the Agreement signed by the client and the firm.

 Generally, the custodian holding the client’s account will deduct CWI’s fees and any other custodial fees directly
 from a designated account to facilitate billing provided the client has given written authorization. The qualified
 custodian will send an account statement at least quarterly. This statement will detail all account activity. Fees
 may be deducted from a single designated client account to facilitate billing. In limited circumstances, at the sole
 discretion of CWI, we may agree to invoice you directly for our advisory fee or we may negotiate other fee
 payment arrangements.

 Our annual fee is exclusive of, and in addition to brokerage commissions, transaction fees, and other related costs
 and expenses which will be incurred by the client. However, we will not receive any portion of the commissions,
 fees, and costs. Please see Item 12 – Brokerage Practices for further information on brokerage and transaction
 costs.

 The portfolio management agreement between the client and CWI will continue in effect until either party
 terminates the agreement in accordance with the terms of the agreement. CWI’s annual fee will be pro-rated
 through the date of termination. Should termination occur at any time other than the end of a billing period, any
 unearned, prepaid fee will be refunded to the client.

 Financial Planning Services Fee
 We charge a fee of up to $3,000 for standalone financial planning services. Clients who hire us for portfolio
 management services will receive an offset of the financial planning fee.

 The proposed services and applicable fees will be detailed in an executed financial planning agreement. Fees shall
 be payable upon execution of the financial planning agreement. Under no circumstances will CWI require
 prepayment of a fee more than six months in advance and in excess of $1,200.

 Either party may terminate the financial planning agreement by providing written notice to the other party. In
 the event there are any prepaid, unearned fees at the time of termination, CWI will promptly refund a pro rata
 share to the client.

 Pension Consulting Services Fees
 The compensation arrangement for pension consulting services is based on fixed fees, or a percentage of the plan
 assets. Services will be negotiated on a case-by-case basis. The exact services to be provided, the fee to be paid
 by the client, fee payment arrangements, how to terminate the contract, and other terms will be clearly stated in
 the pension consulting agreement signed by the client and CWI. Clients who choose to have CWI’s fee deducted
 directly from their account must provide authorization. The qualified custodian holding client funds and securities
 will send an account statement on at least a quarterly basis. This statement will detail account activity. Clients are
 encouraged to review each statement for accuracy.

 IRA Rollover Considerations
 As a normal extension of financial advice, we provide education or recommendations related to the rollover of an
 employer-sponsored retirement plan. A plan participant leaving employment has several options. Each choice
 offers advantages and disadvantages, depending on desired investment options and services, fees and expenses,
 withdrawal options, required minimum distributions, tax treatment, and the investor's unique financial needs and
 retirement plans. The complexity of these choices may lead an investor to seek assistance from us.

 An Associated Person who recommends an investor roll over plan assets into an Individual Retirement Account
 (“IRA”) may earn an asset-based fee as a result, but no compensation if assets are retained in the plan. Thus, we

Capital Wealth Investments
Form ADV Part 2A

 have an economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, fees and
 expenses will increase to the investor as a result because the above-described fees will apply to assets rolled over
 to an IRA and outlined ongoing services will be extended to these assets.

 We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you
 regarding your retirement plan account or individual retirement account, we are also fiduciaries within the
 meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
 applicable, which are laws governing retirement accounts. We have to act in your best interests and not put our
 interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests.

 Additional Fees and Expenses
 The fees CWI charges are negotiable based on the amount of assets under management, complexity of client
 goals and objectives, and level of services rendered. The fees are charged as described above and are not based
 on a share of capital gains of the funds of any advisory client.

 All fees paid to CWI for investment advisory services are separate and distinct from the fees and expenses charged
...

Types of Clients - Item 7

 We generally offer investment advisory services to individuals, pension and profit sharing plans and participants,
 trusts, estates, charitable organizations, corporations, and other business entities.

 CWI generally requires a minimum account size of $100,000 to open and manage an advisory account. However,
 in its discretion, from time to time, CWI may accept smaller accounts based on various criteria, such as anticipated
 future assets, related accounts, and other factors.

                       Methods of Analysis, Investment Strategies and Risk of Loss - Item 8

 CWI advisors will use various methods to determine an appropriate investment strategy. We seek to recommend
 investment strategies or products that will give you a diversified portfolio consistent with your investment
 objective. We do this by analyzing the various products, investment strategies, and money management firms to
 which we provide access. That analysis includes a review of the structure, cost, and investment performance
 history of each program.

 We may use one or more of the following methods of analysis and/or investment strategies when providing
 investment advice to you:

      • Fundamental Analysis – Involves analyzing individual companies and their industry groups, such as a
        company’s financial statements, details regarding the company’s product line, the experience and
        expertise of the company’s management, and the outlook for the company’s industry. The resulting data
        is used to measure the true value of the company’s stock compared to the current market value. The
        primary risk of fundamental analysis is that information obtained may be incorrect and the analysis may
        not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities
        prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable
        performance.

      • Technical Analysis – Technical analysis is a technique that relies on the assumption that current market
        data (such as charts of price, volume, and open interest) can help predict future market trends, at least
        in the short term. It assumes that market psychology influences trading and can predict when stocks will
        rise or fall. Technical trading models are mathematically driven based upon historical data and trends of
        domestic and foreign market trading activity, including various industry and sector trading statistics
        within such markets. Technical trading models, through mathematical algorithms, attempt to identify

Capital Wealth Investments
Form ADV Part 2A

         when markets are likely to increase or decrease and identify appropriate entry and exit points. The
         primary risk of technical trading models is that historical trends and past performance cannot predict
         future trends, and there is no assurance that the mathematical algorithms employed are designed
         properly, updated with new data, and can accurately predict future market, industry, and sector
         performance.

      • Charting – Charting is the set of techniques used in technical analysis in which charts are used to plot
        price movements, volume, settlement prices, open interest, and other indicators, in order to anticipate
        future price movements. Users of these techniques, called chartists, believe that past trends in these
        indicators can be used to extrapolate future trends.

 We may use one or more of the following investment strategies when advising you on investments:

      • Long Term Purchases – Securities purchased with the expectation that the value of those securities will
        grow over a relatively long period of time, generally greater than one year. Using a long-term purchase
        strategy generally assumes the financial markets will go up in the long-term which may not be the case.
        There is also the risk that the segment of the market that you are invested in or perhaps just your
        particular investment will go down over time even if the overall financial markets advance. Purchasing
        investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized
        in the short-term in other investments.

      • Short Term Purchases – Securities purchased with the expectation that they will be sold within a
        relatively short period of time, generally less than one year, to take advantage of the securities' short-
        term price fluctuations. Using a short-term purchase strategy generally assumes that we can predict how
        financial markets will perform in the short-term which may be very difficult and will incur a
        disproportionately higher amount of transaction costs compared to long-term trading. There are many
        factors that can affect financial market performance in the short-term (such as short-term interest rate
        changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of
        times.

      • Trading – Trading involves purchasing securities with the idea of selling them relatively quickly. We may
        use this strategy to take advantage of our predictions of brief price swings. A trading strategy creates the
        potential for sudden losses if the anticipated price swing does not materialize, and could result in having
        a long-term investment in a security that was designed to be a short-term purchase, or the potential of
        a loss. We do not anticipate using a frequent trading strategy. However, in the event we recommend this
        strategy for a particular client, they should understand that higher rates of portfolio turnover would likely
        result in an increase in the account’s broker-dealer costs. High portfolio turnover may also result in the
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